Reporting Obligation for the year 2021 – Alternative Investment Funds Managers/Alternative Investment Funds

MAP RMS would like to inform you about the upcoming Reporting Obligations for Alternative Investment Funds Managers (‘AIFMs’) and Alternative Investment Funds (‘AIFs’) for the year 2021, in order to ensure that you will remain compliant at all times.

The table below presents the reporting obligations for the year 2021 with respect to the reporting requirements for AIFs to Cyprus Securities and Exchange Commission (‘CySEC’) and Central Bank of Cyprus (‘CBC’).

 

Reporting Obligation

Recipient

Reporting Deadlines

Description

Annual Sub-threshold AIFM Report

CySEC

31 January 2021

The report must include the requested information as per the Article 110 of the Delegated Regulation (EU) 231/2013.

Risk Based Supervision

Framework (RBS-F)

CySEC

30 April 2021

The purpose of this form is to communicate with CySEC all information needed in order to determine the AIF’s risk level.

 

Annual Audited Report

 

CySEC

30 June 2021

An overview of the AIF’s activities, financial results and remuneration during the year of 2020. For AIFs established in member states (other than Cyprus) must prepare the annual report and be available to CySEC upon request. The Cyprus AIF’s must submit the annual report to CySEC by the designated deadline.

Half-Yearly Report

CySEC

31 August 2021

The report includes balance sheet, income statement, report on activities, material changes and remuneration based on the AIF’s results for the first half of 2021. The Cyprus AIFs must submit the half-yearly report to CySEC by the designated deadline.

Monthly Prevention Statement

CySEC

15 days from the end of each month (First submission: 15 February 2021)

The purpose of the report is to notify CySEC for a) the monthly cash deposits accepted, b) internal suspicious reports and c) the AMLCO’s report to MOKAS

Annual Report of the Money Laundering Compliance Officer

Board of Directors

28 February 2021

The report provides an overall review of the Company’s AML function during the previous year. Moreover, the AMLCO identifies shortcomings/weaknesses in relation to AML and make recommendations for the next year.

CySEC

31 March 2021

Annual Report of the Internal Auditor

CySEC

30 April 2021

The aim of the report is to identify weaknesses in relation to the Company’s internal operations and make recommendations for improvement. The report should be discussed, and the action plan to rectify the weaknesses identified should be agreed and approved. The report must be submitted to CySEC along with the signed board minutes.

Annual Report of the Compliance Officer

CySEC

Upon Request

The report provides an overall review of the Company’s compliance function during the year 2020. Moreover, the compliance officer identifies shortcomings/weaknesses in relation to the Company’s compliance function and makes recommendations for the next year. 

Quarterly Statistics Form (Form QST-MC)

CySEC

15 days from the end of each quarter (First submission: 15 April 2021)

The Form collects statistical information and it is submitted to CySEC on a quarterly basis. Please note that Circular C423 issues by CySEC on 08 January 2021 to provide further details with respect to the submission of the QST-MC for the period up to 31 December 2020 which is due to CySEC by 29 January 2021.

Statistical reporting

CBC

Upon Request

The report provides CBC with information needed for statistical purposes.

FATCA

Tax Department

30 June 2021

Submission of the XML file to the Cyprus Tax Authorities by the designated deadline.

CRS Report

Tax Department

21 July 2021

Submission of the XML file to the Cyprus Tax Authorities by the designated deadline.

Annual Report of the Risk Manager

CySEC

Upon Request

The report provides an overall review of the Company’s risk management function during the year 2020. Moreover, the Risk Manager identifies shortcomings/weaknesses in relation in relation to the Company’s risk management function and makes recommendations for the next year.   

Annual Disclosures to Investors

Investors

Upon initiation of operations/At least annually

The report outlines the Investor’s historic and current participation in the AIF, NAV and NAV per share related information.

Offering Document

CySEC

Upon application for authorization of the AIF and for every material change

The Cyprus AIFs shall submit to CySEC and make available to investors the Offering Document and every material change in the offering document of the AIF as per the AIF Law.

Audited Statement of Eligible Funds

Investors Compensation Fund (ICF)

10 May 2021

AIFMs that provide the services of Section 6 (6) of the AIFM Law shall submit the Audited Statement of Eligible Funds to the ICF in both electronic and original hard copy forms (Form 87-07-07), accompanied with an external auditor’s report (Form-87-07-06).

Minimum Cash Buffer Confirmation

ICF

15 May 2021 – 20 May 2021

Members of the ICF must submit a signed confirmation by the Internal Auditor regarding the cash buffer of 3 per thousand

Annual Fee payable to ICF

ICF

10 July 2021

According to ICF Directive, each member of the ICF should pay an annual fee to cover operational and/or other expenses. The amount of the annual fee shall be notified in writing to the members of the AIF by June 10 of each year.

Ordinary Annual Contribution to the ICF

ICF

10 August 2021

The amount of the annual contribution due shall be notified in writing to the members of the ICF, by no later than 10/06/2021. However, if the ordinary annual contribution is paid by 10 July 2021, a discount of 80% applies (subject to conditions).

Annual Contribution for AIFMs

CySEC

End of the calendar year

Calculation and payment of the Annual Contributions to CySEC at the end of each calendar year, as specified in Appendix II of Directive 124/56-01.

 

In addition to the above reporting obligations, all entities that fall under the scope of Liquidity Stress Testing (LST), which are effective as of 30 September 2020, are obliged to establish an LST policy. (Click here for more information)

Please contact us at info@maprms.com for more information or in case you need any assistance with respect to any of the above reporting obligations.